Netizen9 — Compliance Duty Platform

The net has been closing for fifteen years. Recognise the drift to grift.

Reeve is a practice tool for the people working inside these fields — MLROs, Section 151 Officers, and the teams around them — built to help you recognise the slow slide from ordinary business into something a court, a tribunal or a judge will later call exactly what it was.

See the pattern See Reeve live
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PERSONAL DUTY
ON RECORD

The same tool, used three times

Parliament didn't close this gap once. It closed it three times, using the same legal mechanism each time — strict corporate liability unless you can show you actually tried to stop it. That repetition is the actual story: not a list of new laws, a deliberate, escalating pattern.

2010 — Bribery Act, section 7

Failure to prevent bribery

The original. Before this, a company could plausibly claim it didn't know an agent was bribing someone on its behalf. Section 7 made "we didn't know" irrelevant on its own — strict liability unless you can show adequate procedures.

Origin of the pattern
2017 — Criminal Finances Act

Failure to prevent the facilitation of tax evasion

Same mechanism, applied a second time. Closed the version of the gap where a firm's own staff helped a client evade tax and the company claimed it never authorised it.

Second application
2023 — ECCTA, section 199

Failure to prevent fraud

In force since September 2025. Same mechanism a third time, now applied to fraud generally. Thirteen years after the first version, still the same underlying question: did you actually try to stop it, or just say you would.

The one in force now
2023 — ECCTA, section 196

The identification doctrine reform

A different kind of gap-closer, sitting alongside the trilogy above. Previously a company could only be prosecuted for economic crime if you could prove the board knew — which was nearly impossible for anything but a small company. Now any senior manager acting within their authority can trigger corporate liability. This is the one that ends "too big to prosecute."

Structural, not sector-specific

In their own words

Not a summary of what went wrong. What the judges, the courts and the regulators themselves actually said, when they finally looked closely.

SFO v Glencore Energy UK Ltd

These efforts were somewhat ineffectual and feeble. One of the policies, for example, dates from 2006, but there is no evidence its terms were enforced or their importance emphasised.

Mr Justice Fraser, Southwark Crown Court, 3 November 2022

£182.9m fine, £93.5m confiscation, £4.6m costs — £280.9m total, the largest sum a UK court has ever imposed on a company. Glencore had anti-bribery policies and a compliance officer. The judge found them worthless because nobody had ever checked whether they actually worked.

Good Law Project & EveryDoctor v Secretary of State for Health

Justice must not only be done, but must also be seen to be done.

Mrs Justice O'Farrell, High Court, June 2021 / January 2022

The "VIP lane" for PPE procurement was found unlawful — a breach of the obligation of equal treatment. Worth stating plainly: the court also found the specific contracts would likely have been awarded anyway on merit. The process was unlawful even where the outcome may not have been corrupt — that distinction is the whole point.

Thurrock Council / Rockfire / Toucan Group

Fraudulent misrepresentations.

Thurrock Council's own court filings, 2024

£655m of taxpayers' money into solar farm bond investments promising 6% annual returns. The council declared effective bankruptcy in 2022 with £1.3bn of debt. The solar farms were eventually sold at a £200m loss. The Serious Fraud Office is investigating. Court documents allege the money behind it bought a £13.7m yacht, a £9.1m jet and a £20.75m estate.

LOBO loans — 240 UK councils, circa 2003-2011

The Financial Conduct Authority has said that it has no powers covering the selling of LOBO loans.

FCA position, as reported to Parliament

Brokerage firm Tullett Prebon paid undisclosed kickbacks to Capita when council business was routed through them on Capita's own advice. Broker ICAP paid kickbacks to its own subsidiary, Butlers, under the same arrangement. The regulator's own admission that it had no jurisdiction is the gap this whole timeline exists to close.

The reasonable procedures defence has a name

Every Act in the timeline above turns on one question: were your procedures real, or just written down. That question is never abstract — in every organisation it has a specific person attached to it, whose escalation either happens properly or doesn't. Here's who, for the roles Reeve covers so far.

Financial services
§ 330 POCA 2002 · SMF17

Money Laundering Reporting Officers

You are the "reasonable procedures" defence, in practice. When ECCTA 2023 asks whether a firm genuinely tried to prevent fraud, the honest answer is written in whether your escalations were taken seriously — not in the policy document.

Reeve works through the SAR/DAML chain, personal liability under POCA and ECCTA, and real cases — Wirecard, Greensill, Glencore, Binance — as scenarios your team can actually be tested on.

Open Reeve for MLROs →
Local government
§ 114 LGFA 1988

Section 151 Officers

A different statute doing the same job. Section 114 is a personal, non-delegable duty to report unlawful spending, built precisely so no leader or cabinet can pressure you into silence — Thurrock is what it looks like when that check exists on paper but isn't used in time.

Reeve includes a Treasury "Trust But Verify" calculator for checking a broker's quote against central government borrowing, alongside procurement red flags and the statutory duty itself, worked through as real scenarios.

Open Reeve for S151 Officers →
Public procurement
§ 1-2 Bribery Act 2010

Procurement Officers

No bespoke "procurement officer" offence exists — the exposure runs through the same criminal law that applies to anyone. No de minimis threshold under the Bribery Act — accepting an improper advantage is enough on its own, whether or not it changed the award.

Reeve covers the PA23 threshold and aggregation rules, direct-award and lot-splitting red flags, and where Bribery Act, Fraud Act and misconduct in public office actually attach to a named decision — not just "follow the process."

Open Reeve for Procurement Officers →
More roles are added as the pattern is properly traced through them — NHS counter-fraud, large public-sector contractors and others are being researched, not shipped until the law and the case material earns a place in this timeline.
Case pending